January 01, 2016

Let’s Make a Deal: Twenty Years of EPA’s Audit Policy

Lawrence Culleen and Thomas Glazer

2015 marked the twentieth anniversary of the U.S. Environmental Protection Agency’s (EPA’s) landmark policy statement on “Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations”—or, as it is more commonly known, the Audit Policy. Since EPA issued the Audit Policy in December 1995, it has become and continues to be an important tool for private companies to address violations of federal environmental requirements proactively while achieving significant reductions in penalties they might otherwise face. While the Agency has been sharing less data on the Audit Policy in recent years, EPA records reflect that between 1995 and 2010, nearly 6,200 companies voluntarily disclosed violations at more than 17,000 facilities.

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